GNB CONTENTS

Ethical Management

Practice Guideline for the Executives and staff

For efficient operation, we comply with the range of conduct
and standards.

Article 1 (Purpose)

For the efficient operation of the Code of Conduct, in relation to the performance of duties of the executives and staff, this guideline sets the range of conduct and standards on the permissible scope of all of benefits such as the valuables, treats, entertainment, and convenience to stakeholders and public officials.

Article 2 (Definition of Terms)

The definition of terms used in this guideline are as follows.

  1. ① "Valuables, etc.” refers to anything that falls under the following paragraphs.
    1. A. Any of the property profit such as money, securities, real estates, goods, accommodation tickets, membership cards, admission tickets, discount tickets, invitations, show tickets, and tickets to use real estate properties
    2. B. Provision of entertainment and treats by food, drinks, golf, etc. or convenience by transportation and accommodation
    3. C. All other types of tangible and intangible economic benefits by debt exemption, employment offer, and granting rights
  2. ② Stakeholders: Persons who are in or prospective trading relationships with the company or all natural individuals,
    corporations, and other organizations whose rights or profits are affected by certain behaviors or decisions made by the organization and executives and staff
  3. ③ Socially acceptable level: A universally acceptable level that other executives and staff or ordinary people can understand when making decisions with sound common sense. The degree to which the beneficiary can handle the duties fairly without having burdening
  4. ④ Team leader: Head of each department in the headquarter or head of a branch/office
  5. ⑤ Public officials, etc.: Public officials or persons in public work pursuant to Article 2 of the Act on the Prohibition of Illegal Work Request and Reception/Payment of Valuables (hereinafter Anti Graft Law.)

Article 3 (Valuables)

  1. ① In no case shall you ask for or accept valuables from stakeholders. However, within the socially acceptable level, souvenirs bearing the logo of the stakeholder’s company, - souvenirs generally provided to the attendees at the events organized by the stakeholders are excluded.
  2. ② If you have received valuables unknowingly or were obliged to receive it against your will, you must return it immediately. If it is difficult to return it, you must report it to the team leader (or the division leader).
  3. ③ The team leader (or the division leader) shall process the reported valuables in transparent and proper manner, and report the result to the leader of the Ethics Management Team.
  4. ④ You must not provide valuables to the public officials and stakeholders other than promotional items that have minimal financial value.
  5. ⑤ Food, money for family events, gifts provided to public officers for the purpose of smooth performance of duties, or socialization, courtesy, or condolences shall not exceed the price listed in [Attached Table 1] set forth in the Enforcement Decree of the Anti Graft Law.

Article 4 (Entertainment)

  1. ① Entertainment with the stakeholders can be given and taken within socially acceptable level.
  2. ② You may not receive entertainment in which the value exceeds the socially acceptable level, and if it was inevitable to receive it, you must report it to the team leader (or the division leader) immediately.
  3. ③ You must not provide entertainment in which the cost exceeds the socially acceptable level to the stakeholders, and when providing entertainment, there must be a legitimate business purpose and should not appear inappropriate. When providing entertainment to public officials, it shall be in accordance with Article 3 Paragraph 5.
  4. ④ In case of providing entertainment in which the cost exceeds the socially acceptable level to the stakeholders at the expense of the company money or participating in events that includes the entertainment in which the value exceeds the socially acceptable level, you must obtain approval from the team leader (or the division leader) in advance.
  5. ⑤ The entertainment given to the stakeholders or public officials shall be recorded accurately in the expense report, and the expense report shall include the department, name, position of all participants along with the detailed business purposes for providing the entertainment.

Article 5 (Convenience)

  1. ① You must not receive conveniences such as transportation and accommodations that are paid by stakeholders. However, the convenience given generally to all participants in the event the stakeholder has organized are excluded.
  2. ② If there is no relation to legitimate business purposes or the cost is appropriate, convenience shall not be given to the public officials or stakeholders. When providing convenience to public officials, it shall be in accordance with Article 3 Paragraph 5.
  3. ③ If you have inevitably received convenience in which the value exceeds the permitted range, you must report it to the team leader (or the division leader).

Article 6 (Money for Family Events)

  1. ① You may not notify the family events that occurred to you or colleagues, and notifying it through a third person is also considered as notification by you.
  2. ② If you have inevitably received money for family events from the stakeholders, we recommend it to be within 50,000 KRW, and if more than 100,000 KRW was received, you must return it in full.
  3. ③ Executives and staff shall not provide money for family events to the public officers or stakeholders. When providing money for family events to public officials, it shall be in accordance with Article 3 Paragraph 5.
  4. ④ If it is difficult to return the money for family events that exceeds 100,000 KRW, you must report it to the team leader (or the division leader), and the team leader (or the division leader) shall entrust it to the Ethics Management Team.
  5. ⑤ Ethics Management team shall use the entrusted money for family event for social contribution activity fund, and shall send a letter of request to prevent the recurrence to the provider or the CEO of company the provider is affiliated with.
  6. ⑥ Upon the request from the Ethics Management Team for the evidence of returning the money for family event exceeding 100,000 KRW, the employee must submit the relevant data.

Article 7 (Monetary Transaction)

  1. ① Monetary transaction such as cash loans, all types of guarantee, and real estate leasing must not be made with the stakeholders or public officials for personal convenience or profit.
  2. ② If you have inevitably made monetary transaction with stakeholders without prior acknowledgment, you must report it to the team leader (or the division leader).

Article 8 (Event Sponsorship)

  1. ① When holding events supported by the company such as department-level events or club activities, you must not receive money or valuables for sponsorship from the stakeholders.
  2. ② Receiving conveniences such as vehicles and venue services for the event is also considered as money or valuables for sponsorship.
  3. ③ If you have inevitably received event sponsorship, you must report it to the team leader of your department (or the division leader) or event organizing team leader (or the division leader).

Article 9 (Wrongful Usage of Company Budget)

  1. ① In relation to all execution of expenses for the company, you must not use it for private purposes.
  2. ② Corporate card should be the principal method of payment when executing expenses, and it should be spent in accordance with the purpose of the budget and the standards set by the law.

Article 10 (Obligation to Report)

  1. ① In case of witnessing the violation of the Code of Ethics, Code of Conduct, or this guideline or being offered to be involved in the act of violation, the executives and staff should report it to the Ethics Management Team by using the quickest and most convenient way [Cyber Hotline, etc.].
  2. ② In case of receiving the report or acknowledging that the employee of his department has violated the Code of Conduct or this guideline from any possible route, the team leader must immediately report it to the Ethics Management Team by using the method indicated in Paragraph 1 of this article.
  3. ③ Failure to report even when acknowledging the violation of the Code of Ethics, Code of Conduct, or this guideline can result in the loss of the opportunity to receive proper protection and even be subjected to punishment.
  4. ④ When necessary, Ethics Management Team may confirm the fact on the received item, and the employee related to this must actively cooperate.
  5. ⑤ Ethics Management Team and the executives and staff must not impose disadvantages to the reporter or the informant in any way or disclose their identities.
  6. ⑥ If there is a risk of the reporter or informant receiving disadvantages in personnel, measures such as change of positions may be taken upon the request from them.
  7. ⑦ Executives and staff must keep confidentiality even when they find out about the reporter or the reported event during task or coincidentally, and must not reveal them in any case.
  8. ⑧ If the employee conducted, or was involved in unethical conduct, but reports the fact to the team leader (or the division leader) or Ethics Management Team on his/her own, the penalty or discipline for the act may be reduced.

Article 11 (Rewards and Discipline)

  1. ① The company may reward or pay appropriate amount of compensation to the executives and staff who have contributed to achieving the objectives of this guideline in accordance with the relevant regulation.
  2. ② The company may discipline the executives and staff in accordance with the relevant regulation or take actions abiding by civil or criminal law to the executives and staff who violated this guideline.

Article 12 (Interpretation)

  1. ① The act of violating the Code of Conduct or this regulation by the family members, relatives, and acquaintances using or stealing the name of the employee is also considered as the act by the employee himself/herself.
  2. ② In relation to the compliance with the regulations such as Code of Ethics, when there is a request of date from the Ethics Management Team for the investigation of facts, the executives and staff should actively cooperate in accordance with the principle of good faith.
  3. ③ If there is any question on the parts that are not specifically set forth in the Code of Conduct and this regulation or disagreement on the interpretation of articles, the interpretation by Ethics Management Team shall be followed.

Article 13 (Training and Pledge)

The company shall conduct training on ethical management every year, and the executives and staff shall submit pledges of compliance on ethical management practice guideline and Code of Conduct upon the admission to the company and request by the company.

Article 14 (Monitoring)

The company shall monitor the compliance of ethical management by regularly reviewing the expenses for business trips, entertainment, and other events.

[Attached Table 1] Price of Food, Money for Family Events, and Gifts Based on Enforcement Decree of the Anti Graft Law
[Attached Table 1] Price of Food, Money for Family Events, and Gifts Based on Enforcement Decree of the Anti Graft Law table consists of separate and positive ranges.
Category Price Range
1. Food: Meals, refreshments, liquor, beverages, and its equivalent that are shared with providers and public officials 30,000 KRW
2. Money for Family Events: Money for congratulation and condolences and flower frame, condolence flower, and its equivalent that replaces this money 100,000 KRW
3. Gifts: All items excluding cash, gift certificates, and equivalent items

However, according to Article 2, Paragraph 1, Item 1 of the [Agricultural and Fishery Product Quality Management Act], agricultural and fishery products as defined in Article 13, Item 13, and processed agricultural and fishery products, as well as gift certificates related to them, are limited to 150,000 Korean won (during the periods specified in Article 17, Paragraph 2, (24 days before and 5 days after) “Seol” and “Chuseok”, up to 300,000 Korean won). 		50,000 KRW

Remarks

  1. ① The price range of each in No. 1 Food, No. 2 Money for Family Events, and No. 3 Gifts shall be the amount summed up items in categories of each No.
  2. ② If both No. 1 Food and No. 3 Gifts were received, the price range shall be added up. In this case, the price range shall be 50,000 KRW, and the price range of No. 1 and No. 3 shall not be exceeded.
  3. ③ If both No. 1 Food and No. 2 Money for Family Events were received, or both No. 2 Money for Family Events and No. 3 Gifts were received, the price range of each shall be added. In this case, the price range shall be 100,000 KRW, and the price range according to the regulation of No. 1 and No. 3 shall not be exceeded.
  4. ④ If all No. 1 Food, No. 2 Money for Family Events, and No. 3 Gifts were received, the price range shall be added up. In this case, the price range shall be 100,000 KRW, and the price range according to the regulation of No. 1 and No. 3 shall not be exceeded.